List of Prepaid Finance Charge Fees on the TIL

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Question:

Can you give me a list of fees that should be included as a prepaid finance charge on the TIL?

Answer:

Most compliance managers and reviewers have such a list, and one or more good ones can be found in the "Bankers Tools". Borrowed lists are a good beginning point, but it's your duty to check for feathers, webbed feet, and the characteristic "quack" that confirms each fee meets the Reg. Z definition. Lenders dream up all kinds of names for fees, but the words you paste on each fee carry no weight when determining if the fee is a FC or not.

First published on BankersOnline.com 5/10/10